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DRAFT ENVIRONMENTAL MANAGEMENT PLAN (EMP)

For the

PROPOSED CONSTRUCTION OF AN ESKOM GENERAL LANDFILL

AND A HAZARDOUS WASTE STORAGE FACILITY IN LEPHALALE,

LIMPOPO PROVINCE

May 2009

DEAT Reference Number: 12/12/20/1399

PREPARED FOR:

Eskom Holdings (Pty) Ltd

Eskom Generation Division

P O Box 1091

Johannesburg

2000

Tel: (011) 800-2706

Fax: (011) 800 -3791

COMPILED BY:

Envirolution Consulting (Pty) Ltd

PO Box 1898

Sunninghill

2157

Tel: (0861) 44 99

Fax: (0861) 62 62 22

E-mail: [email protected]

Website: www.envirolution.co.za

Copyright Warning -

With very few exceptions the copyright of all text and presented information is the exclusive property of Envirolution Consulting. It is a criminal offence to reproduce and/or use, without written consent, any information, technical procedure and/or technique contained in this document. Criminal and civil proceedings will be taken as a matter of strict routine against any person and/or institution infringing the copyright of Envirolution Consulting (Pty) Ltd Reg. No. 2001/029956/07.

Environmental Management Plan

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Eskom Landfill EIA May 2009 Compiled by Envirolution Consulting

TABLE OF CONTENTS

1. INTRODUCTION AND BACKGROUND ......................................................................... 3

2. PHASES OF THE PROJECT ......................................................................................... 5

2.1. The Planning Phase .................................................................................................... 5

2.2. The Construction Phase .............................................................................................. 5

2.3. The Operational Phase ................................................................................................ 5

3. Management Procedures ............................................................................................. 6

3.1. Organisational Structure and Responsibility .............................................................. 6

4. ENVIRONMENTAL MANAGEMENT PLAN (EMP) ...................................................... 17

3. WASTE MANAGEMENT PLAN ................................................................................... 44

6. CONCLUSION.............................................................................................................. 50


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1. INTRODUCTION AND BACKGROUND

Envirolution Consulting (Pty) Ltd (Envirolution Consulting) has been appointed by

Eskom Generation Environmental Management (GEM) Division as an independent

environmental consultancy to undertake the Environmental Impact Assessment (EIA) for

the proposed construction of a general landfill and temporary hazardous waste storage

facility in Lephalale, Limpopo Province.

Eskom is currently constructing a 6 x 800MW coal-fired power station about 15 km from

the town of Lephalale. This station is known as the Medupi Power Station and is in close

proximity of the existing Matimba Power Station and the proposed Coal 3 and 4 Power

Stations in the Waterberg.

Per the legal requirements, all waste materials from Medupi’s construction must be

disposed of in an appropriately licensed waste dump site. There is currently a waste site

at the town of Lephalale, but this site is not licensed and can thus not be used for the

disposal of the Medupi’s waste. As a result Medupi’s waste has to be transported to the

Gauteng region to be disposed of at a licensed site. Due to the volume of waste

produced, this is not a most cost-effective nor is it a sustainable solution.

As part of an environmental impact assessment, risks to the environment are identified.

These possible risks should be taken into account during the planning phase of the

development. As such Environmental Management Plan (EMP) is developed. An EMP

is a requirement for any proposed project as per the NEMA EIA Regulations, 2006. The

implementation of this EMP, through the appointed contractor, remains the responsibility

of the applicant, Eskom.

In their approval of the Scoping Report and Plan of Study for EIA, the DEAT did not

specify a Waste Management Plan (WMP) for this EIA. Envirolution Consulting

however has considered the compilation of a WMP. This will be al document in addition

to the EMP to specifically address the management of general and hazardous wastes

during both the construction and operational phases.

The purpose of the WMP is also to provide guidance to the project team with regard to

the management of waste generated on the construction site during the construction of

the landfill and temporary storage facility. The WMP will further assist in the prevention

of pollution that may arise from the general and the hazardous waste that could be

generated on the construction site.

Appended to this EMP is an Operational plan (Appendix 1a) and Alien Plant

Eradication Programme (Appendix 1b) that must be considered and implemented

where applicable during construction and operational phases of the proposed

development. These documents must be read in conjunction with this EMP and the

specifications therein be implemented.


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In general, the purpose of this EMP is to formulate mitigatory measures that should be

made binding to all contractors during construction of the proposed development, as

well as measures that should be implemented during the operational phase.

The EMP is thus required to protect the natural, social and socio-economic environment

during construction. This EMP is intended for the management of the impacts of

construction of the landfill and the waste storage facility and operation thereof,

rehabilitation and revegetation of affected areas only. This EMP is, therefore, a stand-

alone document, which must be used on site during each phase of the development

(planning, construction and operational phases).

This document should be flexible so as to allow the contractor and Eskom to conform to

the management commitments without being prescriptive. The management

commitments prove that the anticipated risks on the environment will be minimised if

they are adhered to consistently. The onus set out in the EMP rests with Eskom, main

Contractor and subcontractors, which promotes responsibility and commitment. Any

parties responsible for transgression of the underlying management measures outlined

in this document will be held responsible of non-compliances and will be dealt with

accordingly.

The EMP has been developed with due reference to the following:

• Department of Environment Affairs and Tourism, (May 2009). Scoping and

PoS for EIA Approval letter for the Proposed Construction of Eskom

General Landfill and Hazardous Waste Storage Facility, DEAT

Reference No: 12/12/20/1399

• Department of Water Affairs and Forestry, Republic of South Africa,

Bredenhann L, Fourie H.O. (Dr). (1998) Waste Management Series,

Minimum Requirements for the Handling, Classification and Disposal

of Hazardous Waste, Second Edition.

• Department of Water Affairs and Forestry, Republic of South Africa,

Bredenhann L., Ball J.M. (1998). Waste Management Series, Minimum

Requirements for Waste Disposal by Landfill, Second Edition.

• Envirolution Consulting (Pty) Ltd. (March 2009). Environmental Scoping

Report for the Proposed Construction of an Eskom General Landfill

and Hazardous Waste Storage Facility, DEAT Reference No:

12/12/20/1399.


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This document has also been based on the findings of the on site assessment undertaken by

the Envirolution Team and the Specialist Investigation team between November 2008 –

March 2009 for this project.

All the Environmental specifications and the procedures discussed in this document were

also developed in accordance with the relevant legislation applicable to the proposed

development.

2. PHASES OF THE PROJECT

The process which was followed in compiling this EMP is in compliance with NEMA EIA

Regulations 2006, and applies the principles of Integrated Environmental Management

(IEM). The purpose of this EMP is to formulate mitigation measures that are made binding

on all contractors during the construction phase as well as during the operational phase.

The point of departure for this EMP is to take a pro-active route by addressing potential

problems before they occur. This should limit corrective measures needed during the

construction and operational phases of the development. Additional mitigation will be

included throughout the project’s various phases, as required and if necessary.

This EMP deals with the following phases as detailed below:

2.1. The Planning Phase

This EMP offers an ideal opportunity to incorporate pro-active environmental management

measures with the goal of attaining sustainable development. While there is still the chance

of accidental impacts taking place; however, through the incorporation of contingency plans

(e.g. this EMP) during the planning phase, the necessary corrective action can be taken to

further limit potential impacts.

2.2. The Construction Phase

The bulk of the impacts during this phase will have immediate effects (e.g. noise, dust and

water pollution). If the site is monitored on a continual basis during the construction phase, it

is possible to identify these impacts as they occur. These impacts can then be mitigated

through the contingency plans identified in the planning phase, together with a commitment

to sound environmental management from Eskom.

2.3. The Operational Phase

By taking pro-active measures during the planning and construction phases, potential

environmental impacts emanating during the operational phase will be minimised. This, in


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turn, will minimise the risk and reduce the monitoring effort, but it does not make monitoring

obsolete.

3. Management Procedures

3.1. Organisational Structure and Responsibility

3.1.1 Functions and Responsibilities for the Construction Phase

Formal responsibilities are necessary to ensure that key procedures are executed. Specific

responsibilities of the Eskom Project manager, Site Manager, Environmental Manager and

Environmental Control Officer for the construction phase of this project are as detailed below.


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The Project Manager will:

• Ensure that Eskom and the Contractor are aware of all specifications, legal constraints

and Eskom standards and procedures pertaining to the project specifically with regards to

the environment.

• Ensure that all stipulations within the EMP are communicated and adhered to by Eskom

and its Contractor(s).

• Monitor the implementation of the EMP throughout the project by means of site

inspections and meetings. This will be documented as part of the site meeting minutes.

• Be fully conversant with the Environmental Impact Assessment for the project, the

conditions of the RoD, and all relevant environmental legislation

The Site Manager: Matimba Power Station:

• Be fully conversant with the Environmental Impact Assessment.

• Be fully conversant with the conditions of the RoD.

Project Manager

Site Manager

Environmental Control Officer

Environmental Manager/Contractor/

Consultant

Environmental Monitoring Committee


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• Be fully conversant with the Environmental Management Plan.

• Be fully conversant with all relevant environmental legislation and Eskom environmental

policies and procedures, and ensure compliance with these.

• Have overall responsibility for the implementation of the EMP.

• Ensure that audits are conducted to ensure compliance to the EMP.

• Liaise with the Project Manager or his delegate, the Environmental Control Officer and

others on matters concerning the environment.

• Prevent actions that will harm or may cause harm to the environment, and take steps to

prevent pollution on the site.

• Confine activities to the demarcated construction site.

The Environmental Manager will:

• Ensure daily inspections to determine compliance with RoD and CEMP, using checklists

• Submit monthly audit update report to Eskom, External Auditor & Project Management,

showing progress with closure of findings

• Facilitate reporting, recording, investigation and follow-up of environmental related

incidents as per Risk Management process

• Facilitate and integrate relevant training programs for personnel covering all activities

impacting on the environment

• Ensure that the environmental commitments in this Environmental Management Plan and

RoD are complied with by the contractor and its sub-contractors

• Review construction methods, techniques and procedures, identify environmental risk,

draw conclusions and recommend possible solutions

• Develop, implement and manage the necessary construction & operational EMS

• Proactively interpret and objectively analyse environmental data and initiate programs to

mitigate against the environmental and related risks

• Assume a leading role in performing environmental audits and guiding other staff in the

performing of external and internal audits

• Perform monthly environmental reporting for input into Divisional management

information reports

The Environmental Control Officer will:

• Be fully conversant with the Environmental Impact Assessment Report (EIR).

• Be fully conversant with the conditions of the Record of Decision (RoD).

• Be fully conversant with the Environmental Management Plan.

• Be fully conversant with all relevant environmental legislation and Eskom environmental

policies and procedures, and ensure compliance with them.


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• Ensure that periodic environmental performance audits are undertaken on the project

implementation.

• Submit an environmental compliance report on a two-monthly basis, in writing, to the

Director-General of the DEAT, copied to the Limpopo Department of Economic

Development, Environment and Tourism.

• Maintain the following on site:

� A daily site register

� A non-conformance register (NCR)

� A public complaint register

� A register of audits

• Remain employed until the completion of the construction phase.

• Report to project manager and be accountable to the EMC.

In addition, the Environmental Control Officer will:

• Convey the contents of this document to the site staff and discuss the contents in detail

with the Project Manager and Contractor.

• Undertake regular and comprehensive inspection of the site and surrounding areas in

order to monitor compliance with the EMP.

• Take appropriate action if the specifications contained in the EMP are not followed.

• Monitor and verify that environmental impacts are kept to a minimum, as far as possible.

• Ensure that activities on site comply with all relevant environmental legislation.

• Compile progress reports on a regular basis, with input from the Site Manager, for

submission to the Project Manager, including a final post-construction audit carried out by

an independent auditor/consultant.

Generation Environmental Manager will:

• Provide overall assurance to the Managing Director: Generation Division (and hence

ultimately the CEO) that environmental issues are appropriately addressed and managed

at the construction site

• Provide overall assurance to the Managing Director: Generation Division that conditions

in the Record of Decision (RoD) and EMP are adhered to

• Ensure that appropriate reporting of environmental performance/issues takes place

• Where necessary, liaise on a strategic level with environmental authorities on RoD/EMP-

related issues (insofar as construction-related non-compliance is concerned)

Contractors and Service Providers:

All contractors (including subcontractors and staff) and service providers are ultimately

responsible for:


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• Complying with the environmental management specifications where applicable;

• Provide Environmental; Method Statements to the Site Manager with regards to how

certain activities on-site will be conducted.

• Adhering to any environmental instructions issued by the Site Manager/Project Manager

on the advice of the ECO;

• Submitting a report, in a format and frequency as decided upon by the Project/Site

Manager, which will document all incidents that have occurred during the period before

the site meeting

• Arrange that all his employees and those of his subcontractors receive training. Training

has to be appropriate for the level of the tasks and functions undertaken.

The Environmental Method Statement referred to above will cover applicable details with

regard to:

• Construction procedures;

• Materials and equipment to be used;

• Getting the equipment to and from site;

• How the equipment/material will be moved while on-site;

• How and where material will be stored;

• The containment (or action to be taken if containment is not possible) of leaks or spills of

any liquid or material that may occur;

• Identified potential impacts of the activity and mitigation measures thereof;

• Compliance/non-compliance with the Environmental Specifications; and

Any other information deemed necessary by the Site Manager.

2.2. Environmental Specifications: Awareness and Competence

It is important to ensure that all personnel have the appropriate level of environmental

awareness and competence to ensure continued environmental due diligence and ongoing

minimisation of environmental harm.

To achieve effective environmental management, it is important that employees, Contractors

and Subcontractors are aware of the responsibilities in terms of the relevant environmental

legislation and the contents of this EMP. Environmental training may typically include the

following:

• Employees must have a basic understanding of the key environmental features of the

construction site and the surrounding environment;

• Employees will be familiar with the requirements of the EMP and the environmental

specifications as they apply to the construction of the power station.


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• Basic training in the identification of archaeological artefacts, and rare and endangered

flora and fauna that may be encountered on the site.

• Awareness of any other environmental matters, which are deemed to be necessary by

the ECO.

• Records must be kept of those that have completed the relevant training.

Training can be done both in a written or verbal format and in an appropriate language, but

will be in an appropriate format for the receiving audience. Where training has been done

verbally, persons having received training must indicate in writing that they have indeed

attended a training session. A regular form of written or verbal testing will have to be

designed.

2.3. Monitoring and Measurement Programme

A monitoring programme will be in place not only to ensure conformance with the EMP, but

also to monitor any environmental issues and impacts which have not been accounted for in

the EMP that are, or could result in significant environmental impacts for which corrective

action is required. Eskom will stipulate the period and frequency of monitoring required. This

will be determined in consultation with relevant stakeholders and authorities. The Project

Manager will ensure that the monitoring is carried out.

The Environmental Control Officer will ensure compliance with the EMP, and to carry out

monitoring activities. The Environmental Control Officer must have the appropriate

experience and qualifications to undertake the necessary tasks. The Environmental Control

Officer will report to the Environmental Monitoring Committee and Site Manager should any

non-compliance be evident or corrective action necessary. Only in severe cases of non-

compliance, or repeated offences, will the Environmental Control Officer be required to report

to the Project Manager.

All instruments and devices used for the measurement or monitoring of any aspect of this

EMP must be calibrated and appropriately operated and maintained.

2.4. General inspection monitoring and reporting

The Contractors’ Responsible Person or Environmental Officer shall

• Inspect the site on a daily basis to ensure that the environmental specifications are

adhered to.

• Provide the ECO and Environmental Manager with a written monthly report, detailing

both compliance with the Environmental Specification as well as environmental

performance .The Environmental and Compliance Report will be made available to


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the Environmental Monitoring Committee (EMC) as and when necessary, should they

request to see it.

• Maintain a record of major incidents (spills, impacts, complaints, legal transgressions,

etc) as well as corrective and preventive actions taken, for submission to the Site

Manager and the ECO/ Environmental Manager at the scheduled meetings.

• Conduct regular internal audits to ensure that the system for implementation of the

Environmental Specification is operating effectively. The audit shall check that a

procedure is in place to ensure that:

o the environmental method statements and the Environmental Specifications

(ES) being used are up to date

o variations to the ES and environmental method statements and non-

compliances and corrective actions are documented

o appropriate environmental training of personnel is undertaken; and

o emergency procedures are in place and effectively communicated to

personnel

The Environmental Officer shall also provide information to the Site Manager or his

representative, as required during external audits conducted by or on behalf of the Site

Manager as part of the auditing programme. The information required will include the reports

of internal audits conducted by the Environmental Officer.

2.5. Non-Conformance and Corrective Action

The monitoring of the construction of the landfill site may identify non-conformances of the

EMP. Non-conformances may also be identified through incidents, emergencies or

complaints. In order to correct these non-conformances, the route course must be

determined and corrective actions must be identified.

2.5.1. Compliance with the Environmental Management Plan, Environmental

Specifications, Environmental Method Statements and/or Record of

Decision conditions

• The EMP will be available on-site at all times.

• All employees on-site will abide by the requirements of the EMP.

• Any members of the construction workforce found to be in breach of any of the

specifications contained within the EMP may be ordered by the Project

Manager to leave the site. The order may be given orally or in writing. Confirmation of

an oral order will be provided as soon as practically possible, but the absence of a written

order will not be cause for an offender to remain on site.

• The Contractor will not direct a person to undertake any activity which would place them

in contravention of the specifications contained within the EMP.


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• Should the Contractor be in breach of any of the specifications contained in the EMP, the

Project Manager will, in writing, instruct the Contractor responsible for the incident of non-

compliance regarding corrective and/or remedial action required, specify a timeframe for

implementation of these actions, implement a penalty and/or indicate that work will be

suspended should non-compliance continue.

• The Environmental Monitoring Committee (EMC) must report to the Director-General of

the Department of Environmental Affairs & Tourism (DEAT) on a bi-monthly basis, insofar

as project compliance to the condition of this Record of Decision, environmental

legislation and specific mitigation requirements as stipulated in the Environmental Impact

Report (EIR) and the Environmental Management Plans is concerned. The report should

be sent to the Director of the Environmental Division as well.

• The applicant must notify the DEAT, in writing, within 24 hours thereof if any condition of

the ROD authorisation cannot, or is not, adhered to. The notification must be

supplemented with reasons for non-compliance.

• Departmental officials will be given access to the property referred to in the ROD

authorisation for the purpose of assessing and/or monitoring compliance with the

conditions contained in the ROD, at all reasonable times.

• Records relating to monitoring and auditing must be made available for inspection to any

relevant authority in respect of this development.

• The DEAT reserves the right to monitor and audit the development throughout its full life

cycle to ensure that it complies with the RoD conditions, as well as mitigation measures

in the final Environmental Impact Report (EIR), addendum report to the EIR and the

construction EMP.

2.6. Documentation and Reporting

The following documentation must be kept on site by the Environmental Control Officer in

order to record compliance with the EMP:

• Record of Complaints;

• Monitoring Results;

• Notification of Emergencies and Incidents; and

• Any other documentation as required by the Record of Decision.

In addition, the Environmental Control Officer shall:

• maintain records to demonstrate compliance to the Environmental Specifications; and

Environmental Method Statements. The Contractor shall ensure that all records of spills,

pollution incidents, spot fines, training details, etc. are copied to the ECO for his/her

records. All documents shall be open for inspection by the ECO.


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2.6.1. Fines and penalties

• The Site Manager may identify a Contractor that is best implementing the Environmental

Specifications and Environmental Method Statements and may make a periodic award

to, or acknowledge, that Contractor.

• Spot fines shall be imposed by the Site Manager on the Contractor if the Contractor is

found to be infringing on this Specification. The Contractor shall be advised in writing of

the nature of the infringement and the amount of the spot fine. The Contractor shall

determine how to recover the fine from the relevant person and/or sub-contractor and/or

supplier. The Contractor shall also take the necessary step (e.g. training) to prevent a

recurrence of the infringement and shall advise the Site Manager accordingly.

• The imposition of spot fines does not replace any legal proceedings the local authorities,

environmental authorities and/or members of the public may institute against the

Contractor.

• Spot fines shall be between R20 and R2000, depending on the severity of the

infringement. The decision on how much to impose will be made by the Site Manager,

and will be final. In addition to the spot fine, the Contractor shall be required to make

good any damage caused as a result of the infringement at his own expense.

• A preliminary list of infringements for which spot fines will be imposed is as follows:

o Moving outside the demarcated site boundaries;

o Littering of the site and surrounds;

o Burying waste on site and surrounds;

o Smoking in the vicinity of fuel storage and filling areas and in any other areas where

flammable materials are stored/used;

o Making fires outside designated areas;

o Defacement of natural features;

o Using the veld for ablution purposes;

o Spillage onto the ground of oil, diesel, etc.

o Picking/damaging plant material;

o Damaging/killing wild animals; and

o Additional fines as determined by the Site Manager and added to this list.

• Receipts for fines paid shall be issued, and the appropriate documentation retained, by

the Site Manager. Money “raised” through fines may be used to fund

environmental/social schemes on-site.


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2.6.2. Environmental Register

The Contractor will report environmental incidents involving Contractor employees and/or the

public:

• Report environmental incidents involving Contractor employees and/or the public

• Report environmental complaints and correspondence received from the public to the

Project Manager or the Environmental Control Officer.

• Record and report incidents that cause harm or may cause harm to the environment to

the Environmental Control Officer.

• Record all hazardous materials used on site.

• Maintain a record of all Hazardous Waste Disposal Manifests detailing the nature of the

hazardous waste disposed of, the hazardous waste classification and the location of the

site to which such waste was sent.

The above records will form an integral part of the Contractors’ Records. These records will

be kept with the EMP, and will be made available for scrutiny if so requested by the Project

Manager or his delegate and the Environmental Control Officer.

The Environmental Control Officer will put in place an Environmental Register to document:

• All environmental complaints and correspondence received from the public, Eskom or the

construction workforce.

• Incidents of non-compliance with the EMP.

• Any other environmental incidents related to the construction phase of the project.

The Environmental Control Officer will ensure that the following information is recorded for all

complaints/incidents:

• Nature of complaint/incident.

• Causes of complaint/incident.

• Party/parties responsible for causing complaint/incident.

• Immediate actions undertaken to stop/reduce/contain the causes of the

complaint/incident.

• Additional corrective or remedial action taken and/or to be taken to address and to

prevent reoccurrence of the complaint/incident.

• Timeframes and the parties responsible for the implementation of the corrective or

remedial actions.


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• Procedures to be undertaken to be applied if corrective or remedial actions are not

implemented.

Copies of all correspondence received regarding complaints/incidents.

2.1. Public Communication and Liaison with I&APs

Eskom must ensure that the public and surrounding communities are informed and updated

throughout the construction phase, or as and when specific issues arise. An appropriate

method of communication shall be decided upon by the Project Manager.

Sufficient signage should be erected around the site (including at the entrance), informing the

public of the construction activities taking place. The signboards should include the following

information:

• The name of the Eskom

• The name and contact details of the site representative to be contact in the event of

emergencies or complaint registration.

2.7. Environmental Monitoring Committee (Lephalale)

Following the issue of a positive authorisation, Eskom must establish an EMC with clear

terms of reference.

The purpose/terms of reference of the EMC is to execute the following:

• To monitor and audit project compliance to the condition of this Record of Decision,

environmental legislation and specific mitigation requirements as stipulated in the

Environmental Impact Report (EIR) and the Environmental Management Plans;

• To make recommendations to the Director-General on issues related to the monitoring

and auditing of the project; and

• The EMC shall decide on the frequency of meetings should a need arise to review the

prescribed frequency. This change should be communicated to the department (DEAT)

for acceptance.

The EMC shall consist of, amongst others, the following members:

• An independent chairperson who has appropriate people and project management skills,

to be appointed by the EMC;

• The ecologist that participated in the EIA process, or any other suitably qualified and

experienced ecologist approved for this purpose by the department;


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• Two representatives of the public: one community member from Marapong and one from

Lephalale;

• The Environmental Control Officer (ECO);

• A senior site manager.

2.7.1. Functional Aspects

• The EMC must meet on a bi-monthly basis from the inception of the project.

• The EMC must report to the Director-General of the Department of Environmental Affairs

& Tourism on a bi-monthly basis (or possibly the Director: Environmental Impact

Evaluation), and the report must deal with matters as specified in the purpose/terms of

reference of the EMC.

• All costs associated with the EMC, shall be borne by Eskom.

• In addition to the purpose of the EMC as set-out above, the TOR for the EMC must

clearly set out roles and responsibilities related to logistical arrangements, administration

and financial arrangements associated with the EMC.

• Upon completion of construction, the role, responsibilities and constitution of the EMC

shall be re-considered and re-established with new terms of reference for the operational

phase of the development.

4. ENVIRONMENTAL MANAGEMENT PLAN (EMP)

The following table forms the core of this EMP for the construction and operational phases of

the development. This table should be used as a checklist on site, especially during the

construction phase. Compliance with this EMP must be audited monthly during the

construction phase and once immediately following completion of construction. This must be

followed up with annual audits for a period of two years during the operational phase.

Draft Environmental Management Plan

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Table 1: Planning Environmental Management Plan for the proposed Waste Disposal site and Temporary Hazardous Waste Storage Facility

Activity / issue Action required Responsible party Frequency

Planning

The construction must conform to both the applicable permit

conditions and the Minimum Requirements associated with the

site classification.

Eskom Continuous

It is the duty of the responsible person to ensure that the Minimum

Requirements for the operation of the landfill site and the Section

20 permit conditions are applied to the degree equal with its class

to the satisfaction of the Department of Water Affairs and Forestry

and the Department of Environmental Affairs and Tourism.

Eskom Continuous

There must be sufficient facilities (plant materials) and resources

(trained labour force) to ensure that the landfill operation can

conform to both the permit conditions and relevant Minimum

Requirements. For example, there should be sufficient trained staff

to monitor, control and record incoming waste where required.

Eskom Continuous

All construction activities within the landfill must be limited to

daylight hours. Should there be a need to undertaken construction

at night, such will require approval from the Project Manager and

the Environmental Monitoring committee be notified of such

intentions.

Contractor Continuous

Appointment and

Duties of ECO

Eskom must appoint an independent Environmental Control

Officer (ECO) who must monitor the contractor’s compliance with

the environmental management plan.

Eskom Once-off

The Eskom must provide the ECO and contractor with a copy of

the EMP.

Eskom Once-off


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The priority of the ECO is to maintain the integrity of the

development conditions outlined in the EMP and must be enforced

and adhered to at all time.

ECO Continuous

The ECO must form part of the project management team and

attend all project meetings.

ECO Continuous

The contractor must ensure that the construction crew attend an

environmental briefing and training session presented by the ECO

prior to commencing activities on site.

ECO, Contractor Once-off

Appointment and

Duties of EO

The contractor must appoint an Environmental Officer (EO). This

person will be required to monitor the situation with a direct hands-

on approach, and ensure compliance and co-operation of all

personnel. He should be fluent in the languages of the employees.

Contractor Once-off

EMP

This EMP must be made binding to the main contractor as well as

individual contractors and should be included in tender

documentation for the construction contract.

Eskom, ECO Once-off

Permits and

Permissions

The Contractor shall ensure that all pertinent permits, certificates

and permissions required for the project have been obtained prior

to any activities commencing on site and ensure that they are

strictly enforced/adhered to. This includes, for example, licence

for storage of flammable liquids and hazardous materials

(obtained from Lephalale Municipality, if applicable) and other

permits and legislative requirements applicable to the project.

Contractor, Eskom Continuous


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The Contractor shall maintain a database of all pertinent permits

and permissions required for the contract as a whole and for

critical activities for the duration of the contract.

Contractor, Eskom.

ECO Continuous

Method Statements

The Contractor shall submit written Method Statements to the Site

Manager for the activities identified by the Site Manager or ECO.

Activities that will require method statements include:

• Concrete pre-cast and batching operation

• Crushing plant operation

• Storage facilities for any hazardous substances

• Emergency procedures

• Site establishment

• Removal and clearing of vegetation

• Materials, equipment and staffing requirements (camp

establishment)

• Transporting the materials and/or equipment to, from and

within the site

• The storage provisions for the materials and/or equipment

• The proposed construction procedure designed to

implement the relevant Environmental Specifications

• Other information deemed necessary by the RE and/or

ECO.

Method Statements shall be submitted at least ten working days

Contractor, RE, ECO

.

As necessary


21



prior to the proposed commencement of work on an activity to

allow the RE (and/or ECO) time to study and approve the method

statement.

The Contractor shall not commence work on that activity until such

time as the Method Statement has been approved in writing by the

Site Manager.

Contractor, Site

Manager, ECO Continuous

The Contractor shall carry out the activities in accordance with the

approved Method Statement.

Contractor, Site


Under certain circumstances, the RE may require changes to an

approved Method Statement. In such cases the proposed changes

must be agreed upon in writing between the Contractor and the

RE, and appropriate records retained.

Contractor, Site



22



Approved Method Statements shall be readily available on the site

and shall be communicated to all relevant personnel. Approval of

the Method Statement shall not absolve the Contractor from any of

his obligations or responsibilities in terms of the EMP

specifications.

Contractor, Eskom

Continuous

Existing Services

and Infrastructure

The Contractor shall ensure that existing services (e.g. roads,

pipelines, powerlines and telephone services) are not damaged or

disrupted unless required by the contract and with the permission

of the RE.

Contractor, Site

Manager, ECO

Continuous

.

The Contractor shall be responsible for the repair and

reinstatement of any existing infrastructure that is damaged or

services which are interrupted.

Contractor As necessary

Such repair or reinstatement will be to the Contractor’s cost and

shall receive top priority over all other activities. Contractor Continuous

A time limit for the repairs may be stipulated by the Site Manager

in consultation with the Contractor Contractor, RE, ECO Continuous

Environmental

incidents

The contractor must take corrective action to mitigate an incident

appropriate to the nature and scale of the incident and must also

rehabilitate any residual environmental damage caused by the

incident or by the mitigation measures themselves.

EO, ECO, Contractor Continuous


23


CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN


24


Table 2: Construction Environmental Management Plan for proposed Waste Disposal site and Temporary Hazardous Waste Storage Facility


Recruitment of

labour

The contractor must make use of local labour where possible in

order to stimulate the local economy.

Contractor Once off

The contractor must appoint one of his employees to act as an

Environmental Liaison Officer. This person will be required to

monitor the situation with a direct hands-on approach. Eskom

internal policies in terms of recruitment of labourers must be

implemented.

Contractor Once off


25



Site establishment

Any construction camp required by the contractor must be

established in an area as agreed with the ECO. The site for the

construction camp must not be in an environmentally sensitive area

such where indigenous vegetation exists, on a steep slope or on

erosive soils. The area must be properly demarcated prior to

establishment to prevent the construction camp from being

unnecessarily large. The camp must be properly fenced. The EO

must liaise with surrounding parties to ensure that the construction

camp is not located in an area where it will cause a nuisance.

ECO, Contractor Once off

The working width of the construction area must be clearly

demarcated by the installation of coloured pegs prior to construction.

Particularly sensitive areas (e.g. areas with vegetation to be

preserved) must be demarcated with danger tape.

ECO, Contractor Once off, monitor

weekly

The lateral spread of the construction must be monitored on a

weekly basis.

ECO, EO, Contractor Monitor monthly

The EO will also be required to monitor unauthorised movement of

construction crew.

EO, Contractor Once off, monitor daily

Site establishment

A general notice board must be erected at the site entrance, as per

DWAF Minimum Requirements for information required to be on the

notice board as per the RoD.

The Eskom should provide dustbins to be used during site

preparation and surveying.

Contractor Once off, monthly, as

and when needed

To prevent excessive disturbance of natural vegetation, the

contractor should use existing disturbed or paved areas wherever

possible.


weekly


26



To prevent the deterioration of surface water quality, the contractor

must provide adequate ablution facilities. Toilets are to be serviced

twice a week as a minimum and as and when required thereafter,

throughout the construction phase. Every effort must be made to

prevent the contamination of surface or sub-surface water.

Contractor Bi-weekly inspections

Site Housekeeping

The Construction site and surrounds are to be maintained in a clean

orderly and presentable condition at all times.

Contractor Monitor Daily

Regular inspections by the Contractor (and ECO) will be undertaken

using checklists to ensure a minimum standard of orderliness is

maintained.

Contractor, ECO Weekly

Construction activities shall avoid causing unnecessary disruption

and nuisance to adjacent landowners and the public as a whole


General: waste

Litter generated by the construction crew must be collected in

rubbish bins and disposed of weekly at registered waste disposal

sites.

EO, Contractor Weekly

All building rubble, solid and liquid waste etc must be disposed of as

necessary at an appropriately licensed refuse facility.

EO, Contractor Once off, as necessary

Ensure that no refuse wastes are burnt on the premises or on

surrounding premises. No fires will be allowed on site, unless in

designated areas approved by the ECO)

EO, Contractor Monitor daily

The construction site must be kept in a clean and orderly state at all

times.

Contractor, Construction

crew

Monitor daily


27



Ensure that no litter, refuse, wastes, rubbish, rubble, debris and

builders wastes generated on the premises be placed, dumped or

deposited on adjacent/surrounding properties during or after the

construction period of the project are disposed of at dumping site as

approved by the Council.

EO, Contractor Monitor daily - weekly

Fire Prevention and

Control

The Contractor shall take all reasonable and precautionary steps to

ensure that uncontrolled fires are not started as a consequence of

his activities on site.

Contractor Daily

The Contractor shall ensure that there is basic fire-fighting

equipment available on site as per requirement of the local

Emergency Services

Contractor, ECO Continuous

The Contractor shall ensure that all site personnel are aware of the

fire risks and how to deal with any fires that occur. This shall

include, but not be limited to:

• Regular fire prevention talks

• Posting of regular reminders to staff.

Contractor, ECO Continuous

Any accidental fires, which occur, shall be reported to the Eskom

Environmental Manager immediately and then to the relevant

authorities.



28



Emergency

Procedures

The Contractor shall submit Method Statements covering the

procedures and response plan for the main activities, which could

generate emergency situations through accidents or neglect of

responsibilities. These situations include, but are not limited to:

• Accidental fires

• Accidental leaks and spillages

• Vehicle and plant accidents

• Blasting (if required)


Accidental leaks and spillages

• The Contractor shall ensure that his employees are aware of

the procedure for dealing with spills and leaks.

• The Contractor shall also ensure that the necessary materials

and equipment for dealing with the spills and leaks is available

on site at all times.


Hydrocarbon spills

• The source of the spill shall be isolated and the spillage

contained using sand berms, sandbags, sawdust, absorbent

material and/or other materials approved by the Site Agent.

• The area shall be cordoned off and secured.

• The Contractor shall ensure that there is always a supply of

absorbent material readily available to absorb/breakdown the

spill.

• The Contractor shall notify the relevant authorities of any spills

that occurs.



29



The Contractor shall assemble and clearly list the relevant

emergency telephone contact numbers for staff and brief staff on the

required procedures.

Contractor Weekly

Hazardous

Substances

If potentially hazardous substances are to be stored on site, the

Contractor shall provide a Method Statement detailing the

substances/materials to be used together with the procedures for the

storage, handling and disposal of the materials in a manner which

will reduce the risk of pollution that may occur from day to day

storage, handling, use and/or from accidental release of any

hazardous substances used.

Contractor, Monitor daily - weekly

Hazardous chemical substances used during construction shall be

stored in secondary containers.

Contractor Monitor daily - weekly

The relevant Material Safety Data Sheets (MSDS) shall be available

on Site. Procedures detailed in the MSDS shall be followed in the

event of an emergency situation.


The Contractor must ensure that all hazardous chemical substances

are labelled, packed, transported and stored in order to avoid the

spread of contamination.

Contractor & Eskom Monitor daily - weekly

All hazardous chemical substance waste must be disposed of in

accordance with the Hazardous Chemical Substances Regulations,

1995 (Regulation 15).

Contractor & Eskom Monitor daily - weekly


30



The waste, resulting from the use of hazardous materials, shall be

disposed of at a hazardous waste disposal site as approved by the

RE. Storage and disposal of waste is regulated through other

legislation, which should be complied with i.e. the Occupational

Health and Safety Act.

Contractor, RE Monitor daily - weekly

Health and Safety

The Contractor shall comply with all standard and legally required

health and safety regulations as promulgated under the

Occupational Health and Safety Act and associated regulations.

Contractor, RE

Daily

The Eskom must provide and maintain personal protective

equipment and facilities to employees working with hazardous

chemical substances.

Eskom, Contractor Daily

Official training in the correct fit, use, care, storage and limitations of

all Personal Protective Clothing, Respiratory and Hearing Equipment

must be given to the employees

Eskom, Contractor Daily

The Contractor shall provide a standard first aid kit at the site office

of each camp and/or at additional identified locations where needed

Contractor Daily

Air Pollution

Unsurfaced roads and temporary roads must be regularly graded

and watered to control dust.

Contractor As and when necessary

Active earth work areas, stockpiles and loads of soil being

transported must be watered to reduce dust.



31



Measure must be taken to immediately mitigate a situation in which

excessive fugitive dust is observed. Works being undertaken must

be undertaken with caution, or phase down while the source is being

actively investigated and suppression measures are implemented.


All areas disturbed during construction that are not required for a

specific activity must be revegetated.


Disturbed soils, slopes and areas of open excavation must be

minimised to avoid wind erosion.


Diesel exhaust emissions from heavy machinery on site (excavators,

front end loaders and hauling trucks) must be controlled and

minimised by regular checks and servicing of vehicles. Any

construction vehicle found to be emitting excessive smoke should be

stopped from the operations for some mechanical attention before it

could continue.


No development will take place within a 100 year floodline. Contractor As necessary

Surface and ground

water

All cells must be lined with an HDPE or GCL liner, or both, which will

prevent the generation of leachate.

Contractor Once off

Run off drains will be installed leading to a leachate dam, for each

phase of the landfill.

Contractor Once off

Construction activities must preferably take place during the dry

winter months. If construction activities take place in the wet months

appropriate measures must be taken to control stormwater and

implemented to prevent erosion.

Eskom Once off


32



Ensure that excavated and stockpiled soil material is stored and

bermed on the higher lying areas.

EO, Contractor Once off

Vegetation clearance must be kept to a minimum to reduce the risk

of siltation.


Adequate provision must be made for sanitation for the construction

workers. Chemical toilets on site are to be emptied weekly.

Eskom, ECO, Contractor Once off

Construction vehicles are to be maintained in good working order, to

reduce the probability of leakage of fuels and lubricants. No

servicing of vehicles is to be undertaken in close proximity to

watercourses.


Construction and the use of construction machinery should be

limited between 06h00 and 18h00 on weekdays . However if

construction activities need to be outside of these times or on

weekends, this needs to be approved by the Project Manager and

the EMC, and Authorities must be informed.

Eskom, Contractor Monitor daily


33



General: noisy

activities

Institute noise control measures throughout the construction phase

for all applicable activities, including the construction times.

•For mobile equipment noise,

-select vehicle routes carefully by means of internalising the roads

•Fit efficient silencers and enclose engine compartments in plant

vehicles

• For fixed plant noise

-Reduce noise at source by damping acoustic treatment, etc.

-Isolate source by enclosure in acoustic building, room, etc.

-Carefully select fixed plant site for remoteness from sensitive areas

-Raise barriers or berms around noisy equipment


Inform the EMC of planned noisy activities outside the timeframes

stated above.

ECO, EO, Contractor Once off, as necessary

Construction activities must abide by the national noise laws and the

municipal noise by-laws with regard to the abatement of noise

caused by mechanical equipment. In the absence of bylaws,

national regulations on noise control must be complied with

Eskom, EO, Contractor Continual

Prior to blasting (if required), the contractor must inform the adjacent

landowners and EMC at least a few days in advance.

EO, Contractor As necessary

Ensure that the construction vehicles are under the control of

competent personnel and are in proper working order.

Contractor Before construction

commences & continual

General: Crime,

safety and security

Ensure that only suitably qualified personnel use construction

vehicles

Contractors Before construction

commences & continual


34



Ensure that the contact details of the police or security company and

ambulance services are available on site.

Contractor Once off, monitor

weekly

Limit access to the construction crew camp to construction workers

through access control.

EO, Contractor Once off, Continual

Ensure that the handling of equipment and materials is supervised

and adequately instructed.

EO, Contractor Continual

Vehicular traffic during construction activities must be limited to a

maximum speed limit of 30 km/hr.


Site notices informing the public of the planned activities must be

placed at visible locations a few days prior to any blasting.


Based on the preferred footprint area chosen for the proposed

landfill site that certain tress and vegetation may need to be

removed. In this case vegetation clearing should only be done where

necessary and areas not required for construction should be

preserved or avoided.

If any trees needs to be removed 4 construction purposes. New

trees should be planted so that there is no net loss of trees.

Contractor, ECO,

Suitable qualified

specialist

As necessary

Tree/Vegetation

removal

The working strip required for the construction of the landfill and

Waste Storage Facility must be effectively monitored to prevent

excessive vegetation removal. By maintaining the maximum amount

of stabilising vegetation, the extent of erosive action will be

contained.

EO, Contractor Monitor weekly


35



Stripping of

vegetation

Should the construction phase occur in the rainy season, the

erection of berms may be necessary in areas prone to erosion (e.g.

steep slopes or erosive soils). These bermed areas must be

monitored frequently for signs of erosion.

EO, Contractor Once off, monitor

weekly

Vegetation to be retained during the construction phase must be

clearly demarcated with danger tape.


The topsoil cleared must be retained. The topsoil contains most of

the inorganic matter, decomposed organisms and nutrients, thus the

removal of the topsoil constitutes a major loss in terms of ecosystem

function. In order to ensure that the minimal amount of soil is

removed with vegetation clearance, it is strongly advised that

vegetation be harvested as close to ground level as possible before

earthworks machinery is utilised. Soil removed in this manner will

contain the existing seed bank, stolons, rhizomes and runners as

well as an additional supply of organic matter that will be beneficial

during the early stages of vegetation reinstatement. Harvested grass

should be retained and used as a mulch to combat erosion.

EO, ECO, Contractor Once off, monitor

weekly

Excavation

Topsoil and subsoil must be placed on opposite sides of the trench

and must be kept separate throughout construction and

rehabilitation.

EO, ECO, Contractor Monitor weekly

Topsoil must not be stockpiled for an extensive period (> 3 months).

This is to prevent the redundance of the existing seed bank as well

as the alteration of the soil characteristics (permeability, bulk density

etc.).

EO, ECO, Contractor Monitor weekly

Erect signs and/or danger tape around the exposed excavations to

warn the public of the inherent dangers.



36



Trucks removing excavated material can cause compaction of soil if

new pathways are created. Vehicles should, therefore, use existing

roads. If the creation of new roads is unavoidable, these temporary

roads should be ripped and re-vegetated after use.

ECO, Contractor Monitor weekly

Removal of

excavated material

Ensure that excavated and stockpiled soil material is stored and

bermed on the higher lying areas of the site and not in any storm

water run-off channels or any other areas where it is likely to cause

erosion or where water would naturally accumulate.

ECO, Contractor Once off, Daily

Stockpiling soil

The areas where excavated soil will be stockpiled must be bordered

by berms to prevent soil loss caused by rain.

EO, Contractor Once off, monitor

weekly

Archaeological material, by its very nature, occurs below ground. The

Contractor should therefore keep in mind that archaeological sites

might be exposed during construction. If any are noticed, construction

personnel must be alerted and must inform the local SAHRA should

they come across any cultural/archaeological findings. Wok should be

stopped in the area until such time when the archaeologist or SAHRA

or both had observed the area and recommended a way forward.


Destruction/protection

of heritage resources

Should any archaeological artefacts be exposed during excavation,

work on the area where the artefacts were found, shall cease

immediately and the ECO shall be notified as soon as possible.


Upon receipt of such notification, the ECO will arrange for the

excavation to be examined by an Archaeologist as soon as possible.

ECO, Contractor As necessary

Under no circumstances shall archaeological artefacts be removed,

destroyed or interfered.

EO, Contractor Continuous


37



Any archaeological sites exposed during construction activities may

not be disturbed prior to authorisation by the South African Heritage

Resources Agency.

ECO, Contractor As necessary

Sensitive environments and natural features within and/or close to a

construction site will be designated as ‘no-go’ areas and will be

subject to the conditions described in the Environmental

Specification

Contractor, ECO As necessary

Protection of

Sensitive

Environments and

Natural Features

Any taxa, especially those of conservation concern (as per the

ecological report) exposed during the construction activities should

be captured for later release or translocation to adjacent suitable

habitat.


Translocation of

sensitive species

All geophytes and medicinal plants from affected vegetation units

must be removed with the necessary permits and established in a

nursery. After construction, the species must be replanted during the

rehabilitation phase. A management plan (to be compiled by the

ECO) should be implemented to ensure proper establishment of ex

situ individuals, and should include a monitoring programme for at

least two years after re establishment (to ensure successful

translocation).


Remove vegetation only within the minimum width necessary for the

excavation of the cable trench.


Aesthetic / visual

Prevent unnecessary removal of vegetation outside the width of the

working area by clearly demarcating the working area.


Remove spoil material from the area once the trench has been filled. Contractor, Construction

crew

Continual


38



Remove vegetation and topsoil and stockpile separately from subsoil

prior to excavation of the cable trench.


Revegetate disturbed ground in the working area by seeding and

spreading of vegetation that has been removed from the trench at

the start of construction.



39


OPERATIONAL ENVIRONMENTAL MANAGEMENT PLAN


40


Table 3: Operational Environmental Management Plan for the proposed Waste Disposal site and Temporary Hazardous Waste Storage Facility


General A maintenance plan for the landfill must be developed to ensuring

that good working order is achieved.

Eskom, ECO Once-off

Monitoring

A monitoring and eradication programme should be put in place

whereby the distribution and abundance of alien and invader fauna

are monitored through fixed trapping points. (Refer to Appendix 1b)

Eskom,

Waste composition,

inventory and

inspection

Landfill operator must ensure that a register is kept throughout the

life of the facility of the quantities and characteristics of the waste

deposited

Eskom, Waste Contractor Continual

Information on waste register must include the origin of waste, type

of waste, date of delivery, identify of the producer or collector,

Landfill operator Continual

Regular visual inspection of the waste at the point of deposit should

be undertaken to ensure that waste is properly sorted/ separated at

the site


Management of

landfill gas and

odours

Emission rates must be reduced by limiting the extent of uncapped

areas on non operational areas of the site


An area or cell should be regularly covered with temporary cover

material to reduce gas emissions from the area. The prompt

covering of malodorous waste to reduce odour problems is a

Minimum Requirement. In extreme cases, odour suppressants such

as spray curtains may be required.

Eskom, Landfill operator Continual


41



Where breached in the cover from which significant volumes of

landfill gas escape are identified by their odour, a proper

investigation is a Minimum requirement. This may be followed by

properly engineered passive or active gas venting and flaring to

alleviate odour problems. Where a gas management system exists

at a site, it must be correctly operated, maintained and monitored to

ensure that any landfill gas emanating from the site is properly

managed.

Eskom, Landfill operator As necessary

Special cells may be constructed for the disposal of putrescible

general wastes. Such wastes should be deposited and covered

immediately with a layer of soil at least 0.5m thick. This will prevent

odours and discourage uncontrolled salvage.


Accidental fires on landfills where burning is not permitted must be

extinguished immediately. Appropriate operational procedures

involving the spreading and smothering of burning waste, rather than

the application of water, must be implemented.


Vehicle entrainment

from unpaved roads

Wet suppression or chemical stabilisation of unpaved roads should

be conducted as and when required or as required by the RoD.


Ensure that unnecessary traffic is reduced Eskom, Contractor As necessary

Employ speed control measures on roads to control dust and

wearing of roads

Eskom, Contractor As necessary

Employ extensive windbreaks around the landfill area can reduce

the particle pollution in the surrounding areas of the landfill

Eskom, Contractor As necessary


42



Health & Safety

An emergency plan (including fire management) must be developed

and implemented; the relevant authority must approve this plan.

Ensure that all fire extinguishers are replaced on or before their

expiry dates.

Eskom Continuous

Site Safety checks should be carried out in accordance with the

pertinent Occupational Health and Safety requirements prior to site

closure.

Eskom, Landfill operator Continuous

Telephone numbers of emergency services shall be posted

conspicuously in the office for use in emergency situations.

Eskom, Landfill operator Continuous

.Light pollution

Security lights are to be angled downwards to avoid disturbance to

adjoining businesses. Illumination of the buildings must take into

account the possible distraction glare might have on motorists.

Eskom Continuous

Night time light sources must be directed away from, conservation

areas, naturally vegetated areas, as this may be the cause of

ecological disturbance.

Eskom Continuous

Stormwater

Management

Storm water, wherever possible, must be allowed to soak into the

land in the area on which the water has been discharged.

Eskom Continuous

The storm water system, especially the discharge points, must be

inspected and damaged areas must be repaired if required.

Eskom Continuous

No waste or refuse must be allowed to access the storm water

infrastructure

Eskom Continuous

Discharge points must be inspected for blockages of any kind; these

must be removed timeously to ensure the efficient operation of the

storm water management system.

Eskom Continuous


43



Excessive quantities of silt laden runoff water must not be allowed to

access the storm water system. In the event that silt runoff occurs off

the development site, the cause of this must be investigated and

suitable mitigation measures employed. This may include the

vegetation of bare areas, installing flow diversion channels in

consultation with an engineer, installing velocity reducing structures

etc.

Eskom Continuous

Where vegetation has been utilised as part of the storm water

management system, it is important to ensure that the vegetation is

maintained for effective infiltration.

Eskom Continuous

Where silt traps have been incorporated as part of the storm water

management system these must be maintained as per the engineers

requirements, the maintenance crew must be informed as to the

correct procedure, in terms of the engineers specifications, how the

silt trap is to be maintained.

The silt trap must be monitored for efficiency; the management body

must consult the engineers should the system not function

adequately.

Eskom Continuous

Great care should be taken to make sure that the sumps do not

overfill, such that they can spill to contaminate the environment.

Eskom Continuous


44


3. WASTE MANAGEMENT PLAN

The Waste Management Plan will be applicable during the Construction and Operational phases of the landfill and the temporary

hazardous waste storage facility and will be for use by the Contractors and the sub contractors that will be involved during the

Construction phase. Although many of the Waste Management procedures have already been included in the general and operation

EMP, the Eskom, Subcontractors, on site workers and other suppliers are expected to adhere to both the specifications of the general

EMP and the WMP procedures for the duration of the contract.

Table 4: Operational Environmental Management Plan for the proposed Waste Disposal site and Temporary Hazardous Waste Storage Facility


Site establishment

The Eskom should provide dustbins to be used during site

preparation and surveying.

ECO, Contractor Once off

Prior to construction commencing, adequate waste bins should be

provided in order to prevent littering on site.

Contractor Monitor weekly

The Contractor must ensure that provision is made for the

separation of waste into categories for easy recycling and disposal

purposes.

Contractor Monitor monthly

The Contractor must liaise with the Local Authority or the

responsible company for the collection of domestic waste on a

weekly basis, depending on the volumes and quantities generated

thereof.

Contractor, EO & ECO Monitor weekly


45



The Contractor must ensure that there is an area that has been

clearly demarcated as a temporal storage for general, hazardous

and recyclable wastes.

Contractor

Monitor weekly

The Contractor must ensure that necessary arrangements are made

beforehand for the safe disposal of hazardous materials generated

on site by an accredited waste company.

Contractor, EO Monitor weekly

The Contractor will also be required to make necessary arrangement

for the storage and collection of recyclable waste that is generated

on site.

EO, Contractor Monitor weekly

Site control,

Demarcation,

Security, Access

Control in Waste

Storage areas

Waste storage areas shall be provided with signs and display boards

which inform everyone entering the site of the demarcated waste

storage areas.

Eskom Once off, monthly

All Waste Storage areas including areas where potentially

hazardous waste is stored shall be adequately fenced in and

secured to prevent any access of public members and unauthorised

people.


weekly

Areas, Containers and Skips identified for the storage of general,

recyclables wastes shall be clearly marked to indicate the intended

purposes i.e., glass only.

ECO, Contractor Once off, Bi-weekly

inspections

Waste composition,

inventory and

inspection

Landfill operator must ensure that a register is kept throughout the

life of the facility of the quantities and characteristics of the waste

deposited.

Eskom, Contractor Monitor monthly

Information on waste register must include the origin of waste, type

of waste, date of delivery, identify of the producer or collector,

ECO, Contractor Daily


46



Regular visual inspection of the waste at the point of deposit should

be undertaken to ensure that waste is properly sorted at receipt

ECO, Contractor Daily

Requirements for

Waste Management

and Collection

Contractors

General waste shall be collected by a recognised service provider

and be disposed off in registered waste site.

ECO, Contractor Monitor Daily

Recyclable waste shall be collected by a recognised recycling

service provider for appropriate recycling purposes.

Contractor, ECO Weekly

Scrap metals, steel, and glass must be collected in separate waste

skips and each container intended for identified recyclable waste

must be clearly marked, i.e. scrap metals only

General: waste

Litter generated by the construction crew must be collected in

rubbish bins and disposed of weekly at registered waste disposal

sites.

EO, Contractor Weekly

All building rubble, solid and liquid waste etc must be disposed of as

necessary at an appropriately licensed refuse facility.


The Contractor must ensure that no refuse wastes are burnt on the

premises or on surrounding premises. No fires will be allowed on

site.


The construction site must be kept in a clean and orderly state at all

times.

Contractor, Construction

crew

Monitor daily

Wet waste should by no means escape from the waste truck whilst

in transit



47



The Contractor must ensure that no litter, refuse, wastes, rubbish,

rubble, debris and builders wastes generated on the premises be

placed, dumped or deposited on adjacent/surrounding properties

during or after the construction period of the project are disposed of

at dumping site as approved by the Council.

EO, Contractor Monitor daily - weekly

The Contractor must ensure the Waste collection vehicles, when

collecting waste from site, are equipped with covers to prevent

waste from being blown off the waste collection vehicle during

transportation.


Wet waste must be contained in such a fashion that whilst in transit,

no liquid escapes from the load area.


If potentially hazardous wastes are to be stored on site, the

Contractor shall provide a Method Statement detailing the

substances/materials to be used together with the procedures for the

storage, handling and disposal of the materials in a manner which

will reduce the risk of pollution that may occur from day to day

storage, handling, use and/or from accidental release of any

hazardous substances used.

Contractor, Monitor daily - weekly

Hazardous

Substances

Hazardous chemical substances used during construction shall be

disposed off appropriately.


Used oil from construction must be collected in drums and stored

properly


48



The waste, resulting from the use of hazardous materials, shall be

disposed off at a hazardous waste disposal site as approved by the

RE. Storage and disposal of waste is regulated through other

legislation, which should be complied with i.e. the Occupational

Health and Safety Act.

Contractor, Site Manager Monitor daily - weekly

The Contractor and the EO must ensure that all persons involved in

waste collection, sorting, transport and disposal have undergone the

necessary training during the operational phase.

Contractor. ECO Once off

Health Risks

The Contractor shall keep records for the regular collection of all

waste types and disposal thereto, details of waste company

responsible for waste collection. An example of such a form is

included in Appendix 2.

Contractor Monitor monthly

Record Keeping Waste storage areas must have adequate provision in place to

prevent fires.


General

No waste shall be retained on site for a period exceeding 14 days Contractor Continuous

Containers must be emptied frequently to avoid rodents, insects or

any other organisms accumulating on the site and becoming a

health hazard to adjacent properties.

Construction crew, ELO Continuous


Compiled by Envirolution Consulting (Pty) Ltd 49


Compiled by Envirolution Consulting (Pty) Ltd

50

6. CONCLUSION

Provided this project is mitigated, as per the EMP, the project will result in impacts

that should not negatively affect the environment. It is the applicant’s responsibility to

ensure that this EMP is made binding on the contractor by including the EMP in the

contract documentation. The contractor should thoroughly familiarise himself with the

requirements of the EMP and appoint an environmental liaison officer (ELO) to

oversee the implementation of the EMP on a day-to-day basis.

Parties responsible for transgression of this EMP should be held responsible for any

rehabilitation that may need to be undertaken. Parties responsible for environmental

degradation through irresponsible behaviour/negligence should receive penalties.

Key issues

• Construction should take place in the dry season (where possible), leaving

enough time for the germination of seeds and revegetation of barren areas

before the onset of the rainy season;

• All hazardous waste must be disposed of at the hazardous waste site and

registers be kept thereof;

• Proper warning tape (e.g. orange danger nets) must be erected to inform public

of the inherent dangers; and

• Should blasting activities be required on certain areas during foundations

excavations, it is important the relevant permits be obtained and that the

adjacent landowners are informed of these planned activities a few days in

advance and that site notices informing the public are strategically placed at

visible locations.



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APPENDIX 2: AN EXAMPLE OF INCIDENT AND ENVIRONMENTAL LOG

ENVIRONMENTAL INCIDENT LOG

Date Env. Condition

Comments

(Include any possible explanations for current condition and

possible responsible parties. Include photographs, records

etc. if available)

Corrective Action Taken

(Give details and attach documentation as far as possible)

Signature



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COMPLAINTS RECORD SHEET File Ref:

DATE:

………………………… Page of …. COMPLAINT RAISED BY:

: CAPACITY OF COMPLAINANT:

COMPLAINT RECORDED BY:

COMPLAINT:

PROPOSED REMEDIAL ACTION:

ECO: _________________ Date: _________________

NOTES BY ECO:

ECO: __________ Date: __________ Site Manager: __________ Date: __________



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APPENDIX 2: EXAMPLE OF WASTE COLLECTION REGISTERS

Site Time Supplier

Details

Waste

Type

Approximate

Quantities

Responsible

persons

Signature

(Supplier)

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